The IRS’s Advance Pricing and Mutual Agreement Program (APMA) is seeking comment on a proposed revision to the template for advance pricing agreements (APAs). The revision is intended to: Facilitate quicker and more accurate drafting of APAs; Provide more guidance to taxpayers in preparing the proposed draft APA that is required as part of an APA Request; Facilitate APMA’s review of draft APAs; and Facilitate the Mutual Agreement process for bilateral and multilateral APAs. To achieve these goals, the template presents menus of options for selection that cover a wide range of situations in order to minimize the need for...